Corporate Taxation Articles To Search this Article Database Enter: Key Word(s), or Code section [e.g. 162(a)], or Regulation section [e.g. 1.162-1] Corporate Taxation International Taxation Real Estate Taxation Tax Controversy and Litigation State and Local Taxation Employee Benefits Executive Compensation Estate and Personal Tax Planning All Articles     Sales-Based Contingent Royalties Are Not a Production Cost Capitalized Under Section 263A Journal of Taxation, July 01, 2010   What is (Not) Income? Nathel v. Commissioner New York Law Journal, June 17, 2010   Ruling Illustrates Treatment of Payments to Settle Litigation New York Law Journal, April 15, 2010   BLAK Affirms the Necessity of Raising Statute of Limitations Defense Early in TEFRA Partnership Proceedings Journal of Taxation, April 01, 2010   Tax Court Decisions on Section 6707A Penalty Deny Prepayment Forum and Extend Statute of Limitations Journal of Taxation, March 01, 2010   Roberts & Holland: Creative Tax Solutions to Complex Business Problems Forbes, January 18, 2010   Drawing a Line -- Information Reporting vs. Malicious Gossip New York Law Journal, December 17, 2009   IRAs Barred From Owning Stock in S Corporation New York Law Journal, October 15, 2009   Gratuitous Transfer to Related Partnership Not a 'Distribution' New York Law Journal, June 18, 2009   Loss Carryovers and Carrybacks When Only Part of a Consolidated Group is Bankrupt: The Garbled Message of PT-1 Communications Journal of Taxation, June 01, 2009   Court Addresses 'Reasonableness' of Compensation New York Law Journal, April 16, 2009   Allocations of Consideration for a Closely Held Business - Muskat v. United States New York Law Journal, February 18, 2009   Private Equity Fund Found Liable for Pension Obligation of Bankrupt Portfolio Company The Journal of Private Equity, January 01, 2009   Ruling Highlights Importance of Drafting to Indemnification New York Law Journal, October 16, 2008   New Legislation Penalizes Deferred Compensation from Certain Foreign Corporations and Partnerships R&H Letter to Clients and Friends, October 15, 2008   Decisions Underline Scope of IRS Summons Power New York Law Journal, August 21, 2008   Shareholder Disputes Give Rise to Tax Disputes New York Law Journal, June 19, 2008   The Short-Term Deferral Rule Can Mitigate the Impact of Section 409A R&H Letter to Clients and Friends, June 11, 2008   What Happened to My Prepayment Forum? The Penalty Problem in TEFRA Partnership Audit Cases Journal of Taxation, May 01, 2008   Forfeiture of Deductions for Failure to File Timely Return: (Swallows Holding, Ltd. v. Commissioner) New York Law Journal, April 17, 2008   Time To Comply With Section 409A Is Running Out R&H Letter to Clients and Friends, April 02, 2008   Ernst & Young: When Must Stocks Be Taken Into Income? New York Law Journal, February 21, 2008   Ruling Has Not Resolved Work-Product Privilege Issue New York Law Journal, October 18, 2007   Recent Developments Related To Nontaxable Spinoffs The New York Law Journal, August 16, 2007   Warrants Not Received 'In Connection With' Performance of Services New York Law Journal, June 21, 2007   The Burden of Persuasion in Tax Litigation New York Law Journal, December 21, 2006   Court Addresses Limitations on Pass-Through of Losses New York Law Journal, August 17, 2006   Applying Section 162(m) To Partnership Remuneration New York Law Journal, April 20, 2006   State Corporate Income Taxes No Longer Make Sense State Tax Notes, April 17, 2006   When Is A Contract An Option? New York Law Journal, December 15, 2005   Gain Clarified in Shareholder Loans to S Corporations New York Law Journal, October 20, 2005   Is Evading Foreign Taxes A U.S. Crime? The Metropolitan Corporate Counsel, September 01, 2005   Impact of Securities Laws on Taxation of Compensation New York Law Journal, August 18, 2005   IRS Shines Spotlight On Executive Compensation Practices The Metropolitan Corporate Counsel, July 01, 2005   New IRS Rules on Written Tax Advice R&H Letter to Clients and Friends, June 08, 2005   How Many Tax Opinions Will You Need: And Where Will You Get Them? The Metropolitan Corporate Counsel, May 01, 2005   Formation, Reorganization, Liquidation of Insolvent Corporations New York Law Journal, April 21, 2005   Should Accounting Firms Be Tax Advisors? The Metropolitan Corporate Counsel, March 01, 2005   Redemption of Stock in Family-Owned Corporation The New York Law Journal, February 17, 2005   Deductibility Limits on Accrued Interest to Related Parties The New York Law Journal, December 16, 2004   A Tax Opinion Is Not A Bulletproof Vest The Metropolitan Corporate Counsel, November 01, 2004   There's No Guarantee: Proposed Regulations on Wholly-Owned LLCs New York Law Journal, October 27, 2004   Exchanges of Short-Term Debt Instruments in Reorganizations New York Law Journal, August 19, 2004   Give and Take -- New Federal, State and City Tax Legislation New York Law Journal, June 25, 2004   'Dover' and the Consequences of Check-the-Box Liquidations New York Law Journal, June 17, 2004   Awarding Scholarships and Disaster Relief to Employees The Metropolitan Corporate Counsel, June 01, 2004   Treatment of Contingent Liabilities Assumed in Purchase of Assets New York Law Journal, February 19, 2004   Roberts & Holland: The Largest Tax Boutique in The Country The Metropolitan Corporate Counsel, January 01, 2004   New Guidance Regarding Tax Treatment of Deemed Liquidations New York Law Journal, December 18, 2003   Mirror, Mirror on the Wall: When a Liability Is an Asset New York Law Journal, October 16, 2003   Reduction of Tax Attributes Following Cancellation of Debt New York Law Journal, August 21, 2003   Requirements for Spinoff Transactions New York Law Journal, June 19, 2003   Transfers to RICs and REITs New York Law Journal, April 17, 2003   New Proposed Rules Will Change Tax Treatment of Acquisition Costs The Metropolitan Corporate Counsel, March 01, 2003   Expenditure Deductions: The Right Track for Capitalization of Costs New York Law Journal, February 26, 2003   New Regulations Regarding Treatment of Transaction Costs New York Law Journal, February 20, 2003   Disclosures Required on 2002 Tax Returns R & H Letter to Clients and Friends, January 10, 2003   Privilege in Tax Matters: Your Accountant v. Your Lawyer? The Metropolitan Corporate Counsel, January 01, 2003   Further Liberalization of Requirements for Corporate Reorganization New York Law Journal, December 19, 2002   IRS Settlement Initiatives Relating to Tax Shelters New York Law Journal, October 17, 2002   Active Trade or Business Requirements for Nontaxable Spin Offs -- Rev. Rul. 2002-49 New York Law Journal, August 15, 2002   When Should a Distribution be Taxed as an Exchange? -- Steel v. Commissioner New York Law Journal, June 20, 2002   Accounting for Prepaid Items: 'U.S. Freightways v. Commissioner' New York Law Journal, April 18, 2002   The 'Device' Test for Spinoffs Under Section 355 New York Law Journal, February 14, 2002   The Hazards of (Mis)allocation of Purchase Price New York Law Journal, December 20, 2001   Step Transactions and Mergers: Rev. Rul. 2001-46 New York Law Journal, October 18, 2001   'Rite Aid': Consolidated Return Loss Disallowance Held Invalid New York Law Journal, August 16, 2001   New Rulings Regarding Corporate Reorganizations New York Law Journal, June 21, 2001   Stock Redemption or Payment of Compensation? New York Law Journal, April 19, 2001   Installment Method Reinstated for Accrual-Method Taxpayers New York Law Journal, February 28, 2001   Supreme Court Addresses Discharge of Debt Income for S Corporation in 'Gitlitz' New York Law Journal, February 15, 2001   What's the Option Worth? New York Law Journal, August 17, 2000   When Is a Merger Not a Merger? New York Law Journal, June 15, 2000   Rules for Product Liability Losses for Consolidated Groups New York Law Journal, April 20, 2000   Important New Rules on QSubs R & H Letter to Clients & Friends, February 28, 2000   Conversion of Corporations to RICs and REITs New York Law Journal, February 17, 2000   IRS Scrambling to Attack Lease Strips Tax Management International Journal, January 14, 2000   Ticket to Work and Work Incentives Act of 1999 New York Law Journal, December 23, 1999   Tax Law's Insolvency Definition Not the Same as Bankruptcy's New York Law Journal, October 12, 1999   New Rules for Purchase Price Allocations in Taxable 'M&A' Transactions New York Law Journal, August 19, 1999   Treasury Brings 'Fast Pay' Arrangements to a Screeching Halt New York Law Journal, June 17, 1999   Administration Proposals: Tax Avoidance and Corporate Tax Shelters R & H Newsletter -- Tax Insights, February 28, 1999   Mergers and Aquisitions from A to Z -- State and Local Tax Considerations PLI - Mergers & Acquisitions 1999, January 11, 1999   Bankruptcy Code Trumps Internal Revenue Code New York Law Journal, December 24, 1998   Laidlaw Taxpayer Crashed and Burned, Losing Billion-Dollar Debt-Equity Case Canadian Tax Journal, December 01, 1998   Colgate Gets the Brush-off from the Third Circuit: Lack of Economic Substance Found in Tax-motivated Installment Sale New York Law Journal, October 22, 1998   Just When You Thought It Was Safe To Go Back In The Water: Recharacterizing Debt as Equity New York Law Journal, August 27, 1998   QSSS Election - Proposed Regulations Regarding S Corporation Subsidiaries New York Law Journal, June 24, 1998   Selling Closely-Held Stock to an Employee Stock Ownership Plan - How Adequate Must the Consideration Be? New York Law Journal, April 23, 1998   IRS Final Regulations Codifying the Continuity of Interest and Continuity of Business Enterprise Requirements Add Flexibility to Corporate Reorganizations New York Law Journal, February 01, 1998   Identifying the Real Owner - Tax Court Revisits Grants of Reciprocal Put and Call Options New York Law Journal, December 24, 1997   To Vote or Not to Vote, That Is The Question. New York Law Journal, October 23, 1997   Corporate Provisions of the Taxpayer Relief Act of 1997 New York Law Journal, August 28, 1997   Employee Sells a Home and Employer Gets a Tax Deduction New York Law Journal, June 26, 1997   Rules on Below-Market and Interest-Free Loans New York Law Journal, April 24, 1997   Continuity of Interest Rules May Be Liberalized - But Can Remain a Trap for the Unwary New York Law Journal, February 27, 1997   'Check-the-Box' Regulations Provide Certainty, Flexibility and New Planning Opportunities R & H Newsletter -- Tax Insights, January 01, 1997